The Penthouse contest rules

NO PURCHASE OR PAYMENT OF ANY KIND IS NECESSARY TO ENTER OR WIN. HOLDING, BUYING OR SELLING $TOWER DOES NOT IMPROVE YOUR CHANCES OF WINNING. VOID WHERE PROHIBITED OR RESTRICTED BY LAW.

1. The Contest

"The Penthouse" (the Contest) is a free, ongoing daily game-of-skill contest played in the PONZI TOWER browser game at ponzitower.com (the Game). Each day, the eligible player whose tower reaches the most floors holds the Penthouse and receives the rent described in section 8 while they hold it.

PONZI TOWER is satire. The companies, investors, loans and in-game cash (¤) in the Game are fictional. In-game cash is points: it has no value, cannot be bought, and cannot be redeemed. The Penthouse rent in section 8 is the only real-world prize of the Contest. The only other real-world payment connected to the Game is the optional Referral Program in Part B, which has its own rules.

2. Sponsor

The Contest is sponsored by [SPONSOR LEGAL NAME], [SPONSOR ENTITY TYPE AND JURISDICTION], [SPONSOR ADDRESS] (the Sponsor). Contact: [SPONSOR EMAIL]. "PONZI TOWER Holdings" is a fictional company in the Game and is not the Sponsor.

The Contest is not sponsored, endorsed or administered by, or associated with, Pump.fun, DEX Screener, X, Cloudflare, any wallet provider, or any company named or depicted in the Game.

3. Contest period

• The Contest runs in daily periods. Each period starts at 00:00:00 UTC and ends at 23:59:59 UTC on the same calendar day (a Contest Day).
• The first Contest Day is 2026-09-28, starting when the Sponsor announces that the Contest is open.
• The Contest continues daily until the Sponsor ends or suspends it under section 13.
• The Sponsor's servers are the official clock.

4. Eligibility

To be eligible you must, at the time of entry and of any payout:

1. be at least 18 years old or the age of majority where you live, whichever is higher [LAWYER TO CONFIRM];
2. not live in, be located in, or be a national of an Excluded Jurisdiction listed in section 5;
3. not be a person or entity on any sanctions list that the Sponsor is required to observe [LAWYER TO CONFIRM: which lists, e.g. OFAC SDN, UK, EU, UN];
4. not be an employee, contractor, officer or director of the Sponsor, or a member of their immediate family or household [LAWYER TO CONFIRM scope], and not enter using any wallet on the Sponsor's team list;
5. control the Solana wallet you sign in with, and be able to receive the Solana token described in section 8.

You are responsible for making sure that taking part is lawful where you are. Using a VPN or other means to hide your location is prohibited and is grounds for disqualification.

5. Excluded Jurisdictions

[LAWYER TO CONFIRM. Placeholder list; nothing below is a legal conclusion.]

• [JURISDICTION] ([REASON, e.g. restrictions on prize contests, skill-game laws, or sanctions])
• [JURISDICTION] ([REASON])
• [JURISDICTION] ([REASON])
• Any jurisdiction subject to comprehensive sanctions that the Sponsor must observe [LAWYER TO CONFIRM].
• Any jurisdiction where the Contest, or receiving the prize, would be unlawful.

The Sponsor may use IP-based and other checks to enforce this section [LAWYER TO CONFIRM whether geoblocking is required, and how].

6. How to enter (free)

1. Go to ponzitower.com/play/.
2. Sign in with a Solana wallet by signing a text message ("Sign in to claim the Penthouse"). Signing in never asks for a transaction, a payment, or access to your funds. Creating a wallet is free.
3. Pass the human check (Cloudflare Turnstile) when asked.
4. Play an online run. A run is eligible (an Eligible Run) only if it:
   • is started while you are signed in and after passing the human check;
   • is played online with the Sponsor's servers: the server generates a secret seed, deals the cards each quarter and enforces real-time quarters;
   • is completed (the tower falls) and recorded by the server during the Contest Day;
   • is not marked "offline", and is not disqualified under section 10.

You may play as many runs as you like, subject to the Game's rate limits. Each Eligible Run is an entry. Holding $TOWER is not required, and it does not affect your score or your chances.

Entry via a player's own automated methods, scripts or bots is not allowed (section 10). If you cannot or do not wish to use the Game's online sign-in, [LAWYER TO CONFIRM whether an alternative method of entry is required, and what it is].

7. Scoring and the Penthouse holder

• Score: the peak floors reached in the run, as recorded by the server. Valuation, lifespan and other statistics don't count.
• The Penthouse holder at any moment of a Contest Day is the wallet that submitted the highest-scoring Eligible Run completed so far that day.
• Tie-break: if two or more Eligible Runs have the same score, the one completed first, by server timestamp, ranks higher.
• At 00:00:00 UTC the Penthouse is vacated and the new Contest Day starts with no holder.
• Records: the current holder (tower name, shortened wallet, score, since when) and every payout are shown at ponzitower.com/penthouse. The server's records are final, subject to section 10.

8. The prize: Penthouse rent

• What it is. Five percent (5%) of the creator fees generated by trading of the $TOWER token on Pump.fun goes to a public Sponsor-controlled wallet, the Penthouse Vault [PENTHOUSE_VAULT]. This routing is fixed on-chain by Pump.fun's fee-sharing feature. The prize is whatever the Penthouse Vault holds when each payout is made.
• Asset. Paid in the BTC token used as the $TOWER trading pair on Pump.fun: a wrapped BTC token on the Solana blockchain (mint [BTC MINT]). It is not bitcoin on the Bitcoin network.
• Value. The amount depends entirely on trading activity. It varies, may be very small, and may be zero. The Sponsor does not guarantee any minimum amount or value. [LAWYER TO CONFIRM how to state an approximate retail value for a variable prize, if required.]
• Cadence. Every 15 minutes (a Tick), the Sponsor's payout program sends the Penthouse Vault's balance to the wallet of the Penthouse holder at that Tick.
• No holder. If there is no Penthouse holder at a Tick (for example just after midnight UTC), nothing is paid and the balance carries over to the next Tick.
• Minimums. Amounts too small to send economically may be carried over to a later Tick. [SPONSOR TO CONFIRM the Penthouse minimum, if any]
• Fees and accounts. The Sponsor pays the Solana network fees for payouts and, where needed, the cost of opening a BTC token account for the winner.
• Start of payouts. Payouts start only after the Sponsor completes a test of the payout program and announces that payouts are live. Until then, rent accumulates in the Penthouse Vault and is paid out at the first live Tick to the holder at that Tick.
• Finality. Payouts are on-chain transfers and are final once sent. Each payout is listed with its transaction signature on ponzitower.com/penthouse and ponzitower.com/rent.
• The prize is not transferable or exchangeable by the Sponsor for any other prize or for cash.

9. Winners' payment wallet

The prize is paid to the wallet you signed in with for the winning run, and only to that wallet. The Sponsor cannot reverse a payment sent to a wallet you no longer control.

10. Fair play, anti-cheat and disqualification

The following are prohibited:

• bots, scripts, automation or input macros;
• modified clients;
• tampering with network traffic or the Game's API;
• exploiting bugs;
• collusion;
• using multiple wallets or identities to get around rate limits or rules;
• entering from an Excluded Jurisdiction;
• any conduct the Sponsor reasonably believes undermines the Contest's fairness.

The Sponsor may, at its reasonable discretion:

• void any run or entry;
• disqualify a wallet or person, temporarily or permanently;
• stop any future payment to them;
• recalculate the Penthouse holder from the remaining Eligible Runs.

Payouts already sent are final on-chain. The Sponsor may request their return where the law allows [LAWYER TO CONFIRM].

Team wallets are excluded automatically. The Sponsor keeps server logs of every Eligible Run (seed, actions, timings) and may review them.

If a technical failure affects the Contest, the Sponsor may:

• pause payouts;
• void affected runs;
• carry the balance over.

Examples of such failures: server errors, network outages, blockchain congestion, payout program faults or wallet compromise.

11. Taxes and verification

• Winners are solely responsible for any taxes on prizes they receive.
• The Sponsor may require information from a winner (for example identity, residence, age or tax forms) before or after a payout, and may withhold payouts until it is received, where required by law or reasonably needed to enforce these rules. [LAWYER TO CONFIRM: tax reporting thresholds and any identity or KYC requirements for pseudonymous wallet winners in each permitted jurisdiction.]

12. Privacy and publicity

• What the Sponsor processes:
  • your wallet address;
  • the tower name and any X handle you choose to provide;
  • run records (seed, actions, timings, results);
  • a one-way hash of your IP address;
  • the result of the human check;
  • basic technical logs.
• Why: to operate the Game and the Contest, prevent cheating, and make payouts.
• What is public: your tower name, shortened wallet address, score and payouts. Blockchain transactions are public by nature.
• Publicity: the Sponsor will not post your X handle without your agreement.
• Referral Program data is listed in section R11.
• See the privacy policy at [PRIVACY POLICY URL] [LAWYER TO CONFIRM: GDPR/UK GDPR/CCPA disclosures, retention periods, data controller identity].

13. Changes, suspension and termination

The Sponsor may change, suspend or end the Contest, or these rules, at any time. For example: for legal reasons, security incidents, cheating or technical failures.

Changes are posted at ponzitower.com/rules with a "last updated" date and apply from then on. Payouts already sent are not affected. Any balance in the Penthouse Vault when the Contest ends will be [SPONSOR TO DECIDE: paid to the last holder / paid at a final Tick / other; LAWYER TO CONFIRM].

14. Limitation of liability and release

[LAWYER TO DRAFT: release, limitation of liability, no warranties for the Game or the payout program, force majeure, the risks of blockchain assets (including volatility and loss of access to wallets), indemnity.]

15. Disputes and governing law

[LAWYER TO DRAFT: governing law, venue or arbitration, class-action waiver if appropriate, and how disputes about the Penthouse holder are raised (e.g. email to [SPONSOR EMAIL] within 7 days of the Contest Day).]

16. Relationship to the token

The Contest is separate from any purchase or holding of $TOWER:

• Entry is free.
• Holding $TOWER doesn't help you win.
• The Contest is not an investment.

$TOWER is a memecoin with no intrinsic value or expectation of financial return. PONZI TOWER is a game; in-game cash has no value and cannot be redeemed. Not financial advice.

Last updated: [DATE] · Part A version 0.2 (draft)

Part B · The Referral Program · Official Rules ("Bring a player. Split the pool.")

TAKING PART IS OPTIONAL AND FREE. NO PURCHASE OR PAYMENT OF ANY KIND IS NECESSARY TO JOIN OR TO TAKE PART. NOTHING IS EVER PAID FOR ANYONE BUYING, HOLDING OR TRADING $TOWER. VOID WHERE PROHIBITED OR RESTRICTED BY LAW. [LAWYER TO CONFIRM wording]

Words defined in Part A (Sponsor, Game, Eligible Run, Excluded Jurisdiction, Tick) mean the same here. Where Part B says nothing, Part A sections 2, 3 (official clock), 9, 12, 14 and 15 apply to the Program as well [LAWYER TO CONFIRM].

R1. What the Program is

The Referral Program (the Program) is an optional program run by the Sponsor. Once a day, the balance of a public Sponsor-controlled wallet, the Referral Vault [REFERRAL_VAULT], is shared between Participants in proportion to the number of new players they brought to the free Game who qualified that day (section R5).

• Where the pool comes from. Five percent (5%) of the creator fees from trading of $TOWER on Pump.fun goes to the Referral Vault. This routing is fixed on-chain by Pump.fun's fee-sharing feature. Referral payments come only from the Referral Vault: never from the holder vault, the Penthouse Vault, new players, purchases or any deposit.
• What it pays for. The Program pays only for bringing new people to play the free Game. It never pays for anyone buying, holding or trading $TOWER. Neither you nor the players you bring need to hold $TOWER, and holding it doesn't change anything in the Program. [LAWYER TO CONFIRM this characterisation]
• Amounts vary with trading and can be zero. The Sponsor does not promise any amount, minimum or value (section R7).

R2. Joining (opt in)

• Taking part is optional. If you don't join, your invite link works as it always has: when a player you invite finishes a run, you both get the Syndicate facade and a line on the Partners board. That is cosmetic, and nothing else.
• To join, go to ponzitower.com/referrals, sign in with your Solana wallet by signing a text message (never a transaction), and tick the box accepting these rules (version 2026-09-28). [LAWYER TO CONFIRM that a checkbox acceptance is sufficient]
• On joining you receive a referral link, ponzitower.com/i/<code>, tied to the wallet you joined with (a Participant). The Sponsor records the rules version you accepted, the time, and a one-way hash of your IP address at joining.
• One Participant per wallet. Participants may not transfer or sell their link or code.

R3. Who can join

To join and to receive any payment you must, at the time of joining and of any payment:

1. be at least 18 years old or the age of majority where you live, whichever is higher [LAWYER TO CONFIRM];
2. not live in, be located in, or be a national of an Excluded Jurisdiction for the Program (section R4);
3. not be a person or entity on any sanctions list that the Sponsor is required to observe [LAWYER TO CONFIRM: which lists];
4. not be on the Sponsor's team (section R9);
5. control the Solana wallet you join with, and be able to receive the token described in section R7.

You are responsible for making sure that taking part is lawful where you are. Using a VPN or other means to hide your location is prohibited and is grounds for disqualification.

R4. Excluded Jurisdictions for the Program

[LAWYER TO CONFIRM. Placeholder list; nothing below is a legal conclusion. This list may differ from Part A section 5, because paid referral programs can be regulated differently from prize contests.]

• [JURISDICTION] ([REASON, e.g. restrictions on paid referral or affiliate programs, consumer-protection or promotion laws, or sanctions])
• [JURISDICTION] ([REASON])
• [JURISDICTION] ([REASON])
• Any jurisdiction subject to comprehensive sanctions that the Sponsor must observe [LAWYER TO CONFIRM].
• Any jurisdiction where the Program, or receiving a payment from it, would be unlawful.

The Sponsor may use IP-based and other checks to enforce this section [LAWYER TO CONFIRM whether geoblocking is required, and how].

R5. Qualified Players

A player you bring counts for you (a Qualified Player) only when all of the following are true:

1. New player, linked to you. The player opened your link, and their wallet then finished its first-ever verified online run in the Game while carrying your link (the link is remembered in that browser for 30 days). You must have joined the Program before that run. A wallet that had already finished a verified run before is not a new player and can't be linked to anyone.
2. A real game, within 7 days. Within 7 days of being linked, the player completes a verified online run (the first one or a later one) that:
   • was played signed in with that wallet;
   • passed the human check (Cloudflare Turnstile);
   • lasted at least 10 quarters;
   • is not "offline" and is not disqualified under section R8.
3. Not you. The player's wallet is not your wallet, and neither wallet is a team wallet or one of the Sponsor's fee wallets.
4. Not your network. The player's network (one-way IP hash) is not the one you joined from, and not one you finished a run from in the previous 7 days.
5. Network cap. No more than 3 players qualify from the same network (IP hash) per UTC day, across all Participants.
6. Your daily cap. You have fewer than 20 Qualified Players that UTC day. Players beyond the cap are shown on the board as "capped" and are not counted for payment.
7. A real wallet. At settlement (section R7), the player's wallet holds at least 0.01 SOL. This is an anti-bot check only: nothing is spent, sent or bought, and $TOWER is not required. A wallet below it is not counted. [LAWYER TO CONFIRM that a minimum wallet balance for the invited player is acceptable] [SPONSOR TO CONFIRM the value]

Each wallet can be brought once, ever, by one Participant. A link that doesn't qualify within 7 days expires. A Qualified Player counts for the UTC day on which they qualified (the Settlement Day). The Sponsor's servers decide each of these conditions, and their records are final, subject to section R8 [LAWYER TO CONFIRM].

R6. Caps and limits (summary)

The Sponsor may change these limits for future days by updating this page [LAWYER TO CONFIRM notice period].

R7. Daily settlement and payment

• When. Once a day, at the first payout Tick at or after 00:00 UTC, the Sponsor's payout program settles each closed Settlement Day that has Qualified Players not yet settled. If more than one day is unsettled (for example after a pause), they are settled in date order [SPONSOR TO CONFIRM how the vault balance is divided between days settled together].
• The pool. The pool is the Referral Vault's balance at settlement, subject to the payout program's per-Tick safety cap (any excess stays in the vault for a later settlement).
• Your share. Your share = the pool × your Qualified Players that day ÷ all Qualified Players that day, rounded down.
• No Qualified Players. If a day has none, nothing is paid and the balance carries over.
• Asset. Paid in the BTC token used as the $TOWER trading pair on Pump.fun: a wrapped BTC token on the Solana blockchain (mint [BTC MINT]). It is not bitcoin on the Bitcoin network. It is sent to the wallet you joined with, and only to that wallet.
• Value. Amounts vary with trading and can be zero. A share may be very small. The Sponsor does not guarantee any minimum amount or value. [LAWYER TO CONFIRM how to describe a variable payment, and whether an approximate value must be stated]
• Small amounts. Shares too small to send economically are carried as "owed" and paid once they pass the minimum. A BTC token account is opened for you (the Sponsor pays the cost) once your owed amount passes a minimum. [SPONSOR TO CONFIRM the minimums]
• Start of payments. Payments start only after the Sponsor completes a test of the payout program and announces that payouts are live. Until then, settlements are calculated and recorded but nothing is sent; each Participant's calculated share is carried as owed and paid once payouts are live. [SPONSOR TO CONFIRM this matches the payout program's dry-run setting]
• Records. Your stats (qualified, pending, capped, paid) are at ponzitower.com/referrals. Each day's board (shortened wallet and counts) and every payment with its transaction signature are public.
• Finality. Payments are on-chain transfers and are final once sent. The Sponsor pays the Solana network fees.

R8. Fair play, anti-abuse and disqualification

The following are prohibited:

• referring yourself, including through other wallets you or your household control;
• using multiple wallets, identities, devices or networks to create or pose as new players;
• bots, scripts, automation, click farms, or paying or rewarding anyone to sign in or play through your link [LAWYER TO CONFIRM];
• VPNs, proxies or other means to get around the network rules, the caps or the Excluded Jurisdictions;
• spam, and posting your link where the platform's rules forbid it;
• misleading promotion. When you share your link you must not: promise or suggest any amount; say or suggest that anyone needs to buy or hold $TOWER; describe the Program, the Game or $TOWER as an investment or a source of money; or pretend to be the Sponsor [LAWYER TO CONFIRM, including whether Participants must disclose that they may receive a share when they post their link];
• any conduct the Sponsor reasonably believes undermines the Program's fairness.

The Sponsor may, at its reasonable discretion:

• reject or void any referral or Qualified Player;
• pause or ban a Participant, temporarily or permanently;
• withhold or cancel shares that have not been sent yet, including owed amounts [LAWYER TO CONFIRM];
• recalculate a day's shares from the remaining Qualified Players before it is settled.

Payments already sent are final on-chain. The Sponsor may request their return where the law allows [LAWYER TO CONFIRM]. The Sponsor keeps server logs (runs, timings, IP hashes, human-check results) and may review them.

R9. Team exclusion

Wallets on the Sponsor's team list and the Sponsor's fee wallets (holder vault, treasury, Penthouse Vault, Referral Vault) cannot join the Program, and players using them are never counted. Employees, contractors, officers and directors of the Sponsor, and members of their immediate family or household, may not take part [LAWYER TO CONFIRM scope].

R10. Taxes and verification

• Participants are solely responsible for any taxes on payments they receive.
• The Sponsor may require information from a Participant (for example identity, residence, age or tax forms) before or after a payment, and may withhold payments until it is received, where required by law or reasonably needed to enforce these rules. [LAWYER TO CONFIRM: tax treatment and reporting of referral payments, thresholds, and any identity or KYC requirements for pseudonymous wallets in each permitted jurisdiction.]

R11. Privacy

• What the Sponsor processes for the Program: your wallet address and referral code; the rules version you accepted and when; a one-way hash of your IP address at joining; for each player linked to you, their wallet, the link and qualifying runs, the IP hash of those runs, the human-check result, and their wallet's SOL balance at settlement (read from the public blockchain).
• Why: to run the Program, prevent self-referral and abuse, and make payments.
• What is public: the daily board (shortened wallet, counts of qualified and capped players) and payments with their transactions. The wallets of the players you bring are not published by the Program.
• Part A section 12 and the privacy policy apply [LAWYER TO CONFIRM retention periods for IP hashes and referral records].

R12. Pausing, changes and ending

• The Sponsor may pause the Program at any time, for example for suspected abuse, legal reasons, security incidents or technical failures. While paused, settlements may be delayed and the Referral Vault's balance carries over. The page ponzitower.com/referrals shows the status (dry run, live or paused). [LAWYER TO CONFIRM]
• The Sponsor may change these rules. Changes are posted here with a new version and a "last updated" date and apply from then on. The Sponsor may ask you to accept the new version before further players count for you. Payments already sent are not affected. [LAWYER TO CONFIRM notice and consent for changes]
• The Sponsor may end the Program. Any balance in the Referral Vault when it ends will be [SPONSOR TO DECIDE: settled for the last days with Qualified Players / other; LAWYER TO CONFIRM].

R13. Liability and disputes

Part A sections 14 and 15 apply [LAWYER TO DRAFT]. Questions about a referral or a settlement must be raised by email to [SPONSOR EMAIL] within 7 days of the Settlement Day [LAWYER TO CONFIRM].

R14. Relationship to the token

The Program is separate from any purchase or holding of $TOWER:

• Joining is free, and nobody you bring has to buy anything.
• Nothing is paid for anyone buying, holding or trading $TOWER.
• The Program is not an investment. [LAWYER TO CONFIRM]

Amounts vary with trading and can be zero.

$TOWER is a memecoin with no intrinsic value or expectation of financial return. PONZI TOWER is a game; in-game cash has no value and cannot be redeemed. Not financial advice.

Last updated: [DATE] · Part B version 2026-09-28 (draft)